✅Relating to a uniform coordination of benefits questionnaire for health benefit plans.
HB 388
✅ HB 388: One Standard Insurance Form for All Health Plans
What it says it does:
HB 388 creates a single, standardized questionnaire for use by all health insurance companies in Texas to determine which plan pays first when a person has more than one. The form will be created by the Texas Department of Insurance and must be used starting February 1, 2026.
What it actually changes:
This bill transfers administrative control over a key insurance form to one state agency. Every health plan in Texas, including Medicaid, CHIP, and local government employee programs, will now be required to use the same coordination-of-benefits form designed by TDI. There is no built-in legislative or public oversight once the form is created.
Who is pushing for it:
Industry-aligned witnesses filed in support, including the Texas Hospital Association, Texas Medical Association, Texas Association of Freestanding Emergency Centers, and insurance lobbyists representing ER groups, insurers, and benefit administrators. TDI also participated in the hearings.
Who benefits:
Large insurance carriers and hospital systems stand to gain from streamlined claims processing. Freestanding ERs and major health providers benefit from faster billing outcomes. TDI gains rulemaking power with broad applicability.
Who gets left out or exposed:
Rural providers, small clinics, and public sector plans such as school district health pools may have little say in how the form is designed. There is no mandated public comment period, and no requirement to revise the form if it proves unworkable for smaller systems.
Why this matters long term:
Centralized form control creates a precedent. Once this form is built, future administrative standards in insurance could follow the same path, bypassing legislative input. This matters because the form controls who pays and when, which affects coverage delays and patient billing.
What to watch next:
Watch how TDI handles stakeholder engagement. Pay attention to whether the final form supports diverse systems and patient types, or favors industry workflows. Also monitor whether future bills use this same approach to expand agency authority without new laws.
Bottom line:
HB 388 looks like a small paperwork fix, but it shifts real authority to a regulatory agency. If implemented fairly, it could reduce billing headaches. If not, it risks becoming one more tool designed by insurers, not for patients.
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#HB388 #TexasPolicy #InsuranceReform #TDIWatch #KnowBeforeYouVote ✅